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ProRail

Spoorbeheerder: aanleg onderhoud en beheer van spoor, capaciteitsverdeling en verkeersleiding

Lobbying Activity

Meeting with Tom Berendsen (Member of the European Parliament)

2 Dec 2025 · Rail network

Response to Connecting Europe through high-speed rail

8 May 2025

ProRail, the Dutch rail infra manager welcomes the upcoming Communication on Connecting Europe through High-Speed Rail. The targets to double HSR traffic by 2030 and triple it by 2050 are ambitious and necessary to meet EU climate, security, and competitiveness goals. Infrastructure Managers (IMs), as owners and operators of railway infrastructure, are essential partners in making this vision a reality. For the Dutch Ministry, ProRail has prepared building blocks for a strategy on international passenger traffic to and from the Netherlands. We have attached this vision. Bottimline is that more needs to be done and can be done on the existing rail infrastructure if conditions are met.
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Response to Technical specification for interoperability relating to the telematics subsystem of the rail system

13 Mar 2025

The Commission has published a draft for the TSI Telematics Implementing Regulation. ProRail (the Dutch Infrastructure Manager) has read the documents with great interest and welcomes initiatives for more transparency and uniformity in the sector. In the annex, we have provided for feedback in detail. Implementation milestones The implementation milestones for the new messages and the new identifiers are not realistic and not consistent. It takes time (and money) to implement, to adapt the Network Statement and to develop the IT tools. For the capacity allocation for timetable 2026, the planning functions must be available in March 2026. In the current text an implementation period of only a couple of months is included. A period of two years seems more realistic. Its hard to value the consequences of the new proposed ontology, since the ontology is not yet published. TSI Telematics and SERA The SERA directive 2012/34/EU obliges infrastructure managers to respect the commercial confidentiality of information provided to them. This stipulation is not adapted, not even in the capacity regulation. This draft TSI Telematics contradicts with this confidentiality obligation by creating obligations to make available working timetable data, train traffic data and train composition data (hereafter data) not only to telematics stakeholders but also to the public. The confidentiality issue should be solved and TSI Telematics and SERA should be aligned. Otherwise, it would lead to many discussions and feasibility issues in practice. The SERA directive gives obligations to the infrastructure managers for providing services and charging fees to railway undertakings. Data can be part of the minimum access package and package 2 and 4. In the draft TSI Telematics there are obligations to provide data free of charge. This contradicts the SERA directive. Public access to working timetable data, train traffic data and train composition data The Data Act 2023/2854 gives the right of access to data to users (and governments). The TSI Telematics creates obligations to make available working timetable data, train traffic data and train composition data (hereafter data) to telematics stakeholders and to the public. The definitions of train traffic data and train composition data are not clear. We dont understand why the TSI Telematics should describe that this type of information is open for the public. What is the benefit for the public? This change is not within the scope as described in 2017/1474 (see for example article 3 (6)). ProRail B.V., KvK 30124359 2/2 National Contact Point ProRail proposes to delete article 20 (5) of the Act. The Member State shall designate a National Contact Point in accordance with this party so that the appropriate resources will be guaranteed. If article 20(5) is in place, a Member State can do nothing and then the resources are probably not rewarded. Copyright and Creative commons licences In the proposal, data is subject to Creative Commons licences. In the first place some of the mentioned data is raw data where copy right protection probably does not apply. Data such as the working timetable traffic, train traffic data and train composition data are data which can be used but cannot be changed by other parties (the Creative common licences (if applicable) states that the data can be changed). References to the Creative Commons licences should be deleted in the regulation. 100% accuracy, completeness, consistency, uniqueness Telematics stakeholders should strive for 100% accuracy, completeness, consistency, uniqueness but this cant be guaranteed in every case. This is not realistic and should therefore not be a strict requirement but a best efforts obligation. Overall the TSI Telematics should give realistic implementation deadlines and should be aligned with other European legislation (e.g. SERA). We hope you will take this feedback into account. John Voppen CEO ProRail
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Response to Evaluation of the Public Procurement Directives

6 Mar 2025

Geachte heer, mevrouw, In de bijlage treft u ProRails inbreng aan. Met vriendelijke groet, Matteo Stainer
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Meeting with Rachel Blom (Member of the European Parliament) and Havenbedrijf Rotterdam NV

1 Oct 2024 · Introductory meeting

Response to Measures to better manage and coordinate international rail traffic to increase the modal share of rail

17 Nov 2023

As a matter of feedback ProRail is happy to provide feedback to the proposal. For this purpose we attach the impact assessments ProRail (in Dutch) has conducted for the Dutch Ministry and also the position paper of EIM, which has our support. Main assessment in English: The optimizations that the European Commission wishes to implement with the proposal are in line with the rail ambitions of the government and ProRail. The proposal: endorses the development of Time Table Redesign for Smart Capacity Management (hereinafter TTR) already initiated by the entire European rail sector and builds on the virtual European Traffic Management Network concept developed by the sector; Also endorses the ongoing development of a European Traffic Management Network (ETMN) with which infrastructure managers are currently shaping improved coordination and cooperation. our reference: RGLGVNG-2072940504-415 2/5 removes the complicated barriers for carriers - namely the differing national rules - when applying for international capacity; achieves - through harmonization of processes - an overall optimization of rail capacity. This, among other things, makes growth possible and better facilitated and also further optimizes control and coordination at major international barriers. aims to improve the provision of information to rail users; and is consistent with and implements the intended sustainability goals. The proposal provides better support to European infrastructure managers in the performance of their tasks. This enables ProRail to deliver and make operational the most optimal logistics plan - from a social economic perspective. This means a logistics plan that: does most justice to the interests of all carriers and other customer wishes; does most justice to the policy objectives; leads to the best use of the railway infrastructure; and leads to the most efficient expenditure of subsidies for railway infrastructure. As briefly mentioned above, this proposal lays the legal basis for the implementation of the improved capacity allocation process known as TTR. ProRail has been involved with TTR from the start and is one of the infrastructure managers in Europe who has proactively started its partial implementation. The proposal largely follows the chosen course. This together with the aforementioned means that ProRail considers the proposal to be a desirable development.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

11 Nov 2020 · Rail travel and Sustainable and Smart Mobility Strategy

Response to Sustainable and Smart Mobility Strategy

5 Aug 2020

Rail transport can play an even more important role in achieving the goals of a carbon free Europe than already envisaged by the European Commission. The Corona crisis has demonstrated that rail freight and passengers transport is of crucial importance to keep crucial medicine, goods and people moved. Recovering from the crisis it is now time for extra investments in green amd safe transport infrastructure to keep employment and reach the climate change goals of the EC. A study, conducted by Rebelgroup for ProRail shows that substitution of intra-EU flights by trains can save up to 8 million tonbs of CO2 emissions on a yearly basis. For further explanation we add the study as an annex and would also like to refer to: - joint statement position paper by the European Railway sector (EIM, CER, UNIFE): https://www.cer.be/publications/latest-publications/joint-statement-rail-sector-forthcoming-strategy-sustainable-and - ministerial declaration on rail passenger corridors June 4
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Response to Schedule for the rail infrastructure capacity allocation process

14 Apr 2017

ProRail, the NL rail infrastructrure manager, understands the importance of making the capacity allocation process more open and transparent and also more harmonised between the different member states. Therefore, ProRail jointly with other IM’s is ready to support the EC in working toward a process which ensures more predictability for the operators and a balance in flexibility for the RU's and IM's managers, while meeting the needs of the market segments and taking into account the operational concerns of all stakeholders involved. ProRail welcomes that, throughout the discussions during the working visit of the EC at ProRail and ever since, the Commission has partially amended its proposal according to the input given by the sector. E.g. the issue of the publication of a working timetable ''in the network statement'', which cannot be implemented in practice, has been resolved and the related provision will be adjusted accordingly. In the latest draft of the DA, the EC still proposes setting up a 2 rounds application period. This is justified with the need to give applicants the chance to submit late requests for capacity to be incorporated in the annual working timetable. Currently, this is not an issue in NL, since we are able to accommodate properly requests during the year. We fear that, in practice, such a system will be too rigid, it will unnecessarily increase the burdens of all stakeholders during the allocation process and it will not deliver on the desired goal. ProRail proposes that capacity requests made at any time after the annual deadline should be taken into account by the IM. IF this leads to complaints, operators can go to the regulator. In order to avoid any possible discrimination, there should only be one common rule for all IM's. On the other hand we miss the option as foreseen in the TTR program for the rolling planning together with safeguarding capacity rules. A big demand of our customers, mainly freight. Because in rail freight, contracts almost never are in the same rhythm as the yearly timetable and a rolling planning makes it possible to do it first time right. When it comes to TCRs, ProRail supports the goal of giving applicants a chance to prepare and adapt to capacity restrictions in due time. In this regard, we strongly urge the EC to take into account the TTR project, and most notably the work on the timeline and obligations of TCR's. The TTR/TCRs project fully reflects the experience made by the sector, as requested in Article 43 of Directive 2012/34/EU. In the EIM-CER joint Position Paper attached to this text, we have built our proposal on the basis of the latest update of the TTR/TCRs project, which was recently amended by RNE after conduction trial runs. Following this further, ProRail understands the EC’s goal to have the new provisions adopted just on time for the TT 2019. We believe however that the proposal contains several provisions which warrant a derogation from the rule proposed by the EC i.e. that the Decision enters into force on the 20th day following its publication. A transition period is all the more necessary because the EC intends to adopt a delegated act taking the form of a DA, thus a transposition by MS's would not be required. ProRail calls on the EC to foresee a transition period for the application of the Act which would allow IMs to adapt to the new rules. Otherwise the IM will not be able to meet all the timelines required by Annex VII (e.g. x-24, X-18, X-12) for the next TT period. We urge not to underestimate the operational difficulties such an obligation would pose on IMs and RUs in terms of HR and IT infrastructure. Therefore, we suggest that the annex becomes effective 2 1/2 years before the working timetable where where the rules have to be applied for the first time. This gives all involved parties sufficient time to do all the necessary preparations.Finally, we would like to invite the EC to read attentively the EIM-CER joint Paper - annex.
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